Environmental, Social & Ethical (ESE) and Reputational Risk Management

Prohibited

Generic

• Evidence of human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation.

Defence

• Financing of companies involved in the manufacture, sale, trade, service or stockpiling Highly Controversial Weapons banned under International Agreements ratified by the United Kingdom (Cluster Munitions, Anti-Personnel Landmines, Biological and Toxin Weapons, Chemical Weapons and Blinding Laser Weapons) and the manufacture or sale of Bespoke Components of such weapons.
• Financing of companies involved in the manufacture, sale, trade, servicing or stockpiling of nuclear weapons in jurisdictions outside NATO countries and that are not officially involved in and accredited to the national nuclear weapons programmes of the UK, US or France.
• Financing of companies involved in the manufacture, sale or trade of defence goods where there is no (defence related) licence in place, and such is required.

Private Security

• Armed PSCs operating in high-risk countries that have not signed up to the International Code of Conduct (ICoC) or other relevant industry body within the next 12 months.
• Armed PSCs operating in low-risk countries that have not adopted ICoC or equivalent standards, policies or procedures.
• PSC’s providing armed personnel to government Armed Forces or local militia (mercenaries).

Prohibited

• Evidence of human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation.
• Soft commodities producers operating in tropical regions who have not obtained sustainable certification of their direct soft commodities activities and supply chain by 31st December 2024. This means obtaining the following certifications and memberships: 1. Forestry, Rubberwood, Pulp & Paper – FSC & PEFC certified 2. Palm Oil – Roundtable on Sustainable Palm Oil (RSPO) 3. Soy – Roundtable for Responsible Soy (RTRS) 4. Beef/Leather – Global Roundtable for Sustainable Beef (GRSB) Leather Working Group (LWG) 5. Cocoa – Rainforest Alliance, Fairtrade
• Manufacture of pesticides banned under the Stockholm Convention. 
• Damaging fishing methods – Use of explosives (dynamite) and/or poison (cyanide). 
• Vessels that carry or use one or more driftnets with an individual or combined length of more than 2.5 kms or use of driftnets intended for the capture of species listed in Annex VIII of EU Regulation 1239/98 such as tuna and swordfish.
• Direct involvement in shark-finning or trading in shark fin; commercial whaling; Illegal, Unreported or Unregulated (IUU) fishing activities or trade in IUU products.
• Harvesting or trade of species listed under the Convention of International Trade of Endangered Species (CITES).
• Direct involvement in illegal logging or the purchase of illegally harvested timber or companies using illegal and/or uncontrolled use of fire for land clearance.
• Tree felling or clearance within High Conservation Value Forests, UNESCO World Heritage Sites or International Union for the Conservation of Nature IUCN (I – IV) Protected Sites.
• Tree felling or tree and mangrove clearance in Ramsar Sites, Man & Biosphere Sites and High Conservation Value Areas.
• Companies with operations that have actual and potential adverse impacts on the Outstanding Universal Value of UNESCO World Heritage Sites.
• Clearing of peat lands for commercial plantations [by draining and/or burning] unless a clear and stringent peat land management procedure is in place. 

The following prohibitions apply when lending to a specific project: 

• Projects involving unsustainable vegetation clearance or peatland clearance/extraction. Our definition is projects involving: 
• Degradation of areas (often forests) necessary to protect High Conservation Value areas. 
• The conversion of primary tropical forests; or land clearance by burning. 
• The conversion of High Carbon Stock tropical forests. 
• Clearance of peatlands, including peat extraction.

Prohibited

• Evidence of human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation. 
• Customers who have not achieved, or not are working towards achieving the GamCare Safer Gambling Standard Advanced Level 2 by the end of 2024.
• The provision of banking services to any gambling company operating in jurisdictions where gambling is not legal.
• Online Gambling Operators who are not in scope of the United Kingdom or Republic of Ireland licensing regimes (including Alderney or Gibraltar). 
• Unlicensed operators where a licence is required.
• Junket Operators.
• Evidence of serious breaches of regulations or licence conditions including financial crime and social responsibility clauses. 

Prohibited

For those customers in scope, evidence of:

• human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation. 

Prohibited

• Evidence of human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation.
• New customer relationships with corporates who explore for, extract or produce coal.
• Existing customers who are increasing coal mining activity by exploring for new coal, developing new coal mines or increasing thermal coal production.
• All project financing (including refinancing) related to coal mining activity by exploring for new coal, developing new coal mines and coal infrastructure.
• Significant producers of coal using Mountain-top Removal (MTR) mining in Appalachia (where the share of the MTR market is over 5% of total market; the company is producing more than 2 million tonnes of coal using MTR methods; the company is out of compliance with environmental and social conditions around MTR activity; or there is a net increase in production of coal using MTR mining).
• Project financing for projects involving the use of Mountain-Top Removal mining methods.
• Companies undertaking artisanal / informal mining.
• Companies involved in the extraction of asbestos.

Prohibited

• Evidence of human rights violations where the customer is unable to demonstrate that it has taken any action to cease, remediate, prevent and/or mitigate, as appropriate, the relevant violation.
• Upstream oil and gas companies where the majority (>51%) of their assets being financed are not based in the UK (onshore or offshore UK Continental shelf).
• Companies involved in onshore exploration, extraction or expansion of oil & gas in the UK using hydraulic fracturing methods (‘fracking’).
• Reserve based lending specifically for the purpose of financing oil and gas exploration, extraction and production for new customers.
• After, the 31st December 2025 we will not renew, refinance or extend existing reserve-based lending specifically for the purpose of financing oil and gas exploration, extraction and production.
• Reserve based lending and borrowing base financing to upstream Oil and Gas companies specifically for the purpose of financing upstream assets located in Arctic or Antarctic Waters.
• Oil and gas majors, unless they had a credible transition plan aligned with the 2015 Paris Agreement in place*.
• Oil and gas majors who do not report to us the overall emissions of the assets they operate by end of 2023.
• Companies involved in onshore or offshore exploration, extraction or expansion of oil and gas facilities outside the UK using hydraulic fracturing methods where the company does not have a licence to operate by the relevant authority or there are repeat compliance issues associated with operations.
• Major oil & gas companies who are not committed to the Global Gas Flaring Reduction Partnership (GGFR) and the World Bank’s “Zero Routine Flaring by 2030” initiative.
• Companies undertaking the exploration, extraction or expansion of oil from Oil Sands (Existing NatWest Group exposure to these activities will only be accepted if it has been assessed as part of the company’s credible transition plan). 
• Companies undertaking the exploration, extraction of expansion of oil and/or gas using coal-bed Methane or Coal Liquefaction (Existing NatWest Group exposure to these activities will only be accepted if it has been assessed as part of the company’s credible transition plan).
• Projects involving oil exploration and production operations in Arctic or Antarctic Waters.
• Project financing of exploration and extraction of oil and gas activity in the Arctic Refuge.
• Projects involving the exploration and extraction of oil from oil sands.
• Projects involving hydraulic fracturing ('fracking') for oil and gas. 
• Projects involving exploration for new oil and gas reserves.
• Projects involving the exploration or production of oil and gas in ultra deep-water.

* as assessed by our point in time credible transition plan assessment methodology undertaken in 2021.